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Kyrgyz Republic: Women's Entrepreneurship Development Project - A2F Consulting
Technical Assistance Consultant’s Initial Report

Project Number: JFPR 9170-KGZ
June 2017

Kyrgyz Republic: Women’s
Entrepreneurship Development Project
(Financed by the Japan Fund for Poverty Reduction and administered by
ADB’s Resident Mission in the Kyrgyz Republic)

Mobile Banking (Bai-Tushum Bank)

Prepared by A2F Consulting, LLC

This consultant’s report does not necessarily reflect the views of ADB or the government
concerned, and ADB and the government cannot be held liable for its contents. (For project
preparatory technical assistance: All the views expressed herein may not be incorporated
into the proposed project’s design.)

Asian Development Bank
Kyrgyz Republic: Women's Entrepreneurship Development Project - A2F Consulting
Women’s Entrepreneurship
  Development Project

     Mobile Banking
Kyrgyz Republic: Women's Entrepreneurship Development Project - A2F Consulting
TABLE OF CONTENTS

Abbreviations .....................................................................................................II
Boxes, Figures and Tables ..................................................................................III

1. INTRODUCTION .............................................................................................. 1
2. MOBILE FINANCIAL SERVICES OVERVIEW........................................................ 2
  2.1. Mobile Financial Services – What is? ............................................................. 2
  2.2. Mobile Financial Services - Ecosystem ........................................................... 4
  2.3. Delivery Channels Evolution .......................................................................... 5
  2.4. Delivery Channels Reach ................................................................................ 6
  2.5. Technology Enablers ...................................................................................... 7
  2.6. Delivery Channels Risks ................................................................................ 10
  2.7. Delivery Channels Regulation ...................................................................... 10
3. FINANCIAL INCLUSION AND MOBILE FINANCIAL SERVICES ............................ 11
  3.1. Mobile Money as a Driver of Financial Inclusion ......................................... 11
  3.2. Mobile Money Services - World Availability ................................................ 14
  3.3. Mobile Financial Services Success Stories .................................................... 18
4. M-BANKING IN THE KYRGYZ REPUBLIC ......................................................... 19
  4.1. Building Blocks of Mobile Banking ............................................................... 19
  4.2. Country Readiness ....................................................................................... 24
5. USE OF M-BANKING IN BAI-TUSHUM BANK .................................................. 26
  5.1. Bai-Tushum Delivery Channels Architecture................................................ 26
  5.2. Why Does It Make Sense for Bai-Tushum Bank? ......................................... 28
  5.2. Mobile Financial Services Business Models ................................................. 28
  5.3. Model Selection Criteria .............................................................................. 30
  5.4. MFS Adoption Constraints in Rural Areas .................................................... 31
6. SUMMARY AND CONCLUSION ...................................................................... 32
ANNEX – LIST OF INTERVIEWEES....................................................................... 34

      A2F Consulting                                                                                               i
Kyrgyz Republic: Women's Entrepreneurship Development Project - A2F Consulting
ABBREVIATIONS
ADB           –      Asian Development Bank
ADC           –      Alternative Delivery Channels
C2C           –      Cash to Cash (money transfer)
C2M           –      Customer top-up mobile account
M2M           –      Mobile to Mobile account transfer (e-money)
M2C           –      Mobile to Customer (electronic to cash transfer)
KGS           –      Kyrgyz Som
DFS           –      Digital Financial Services
e-Wallet      –      Electronic Wallet
e-money       –      Electronic Money
FSP           –      Financial Services Provider
G2P           –      Government to Person
GDP           –      Gross Domestic Product
GNI           –      Gross National income
GSMA          –      Groupe Speciale Mobile Association
ICT           –      Information and Communication Technology
ISP           –      Internet Service Provider
ITU           –      International Telecommunication Union
IVR           –      Interactive Voice Response
m-Money       –      Mobile Money
MFI           –      Microfinance Institution
NBKR          –      National Bank of the Kyrgyz Republic
NFC           –      Near Field Communication
OTC           –      Over the Counter
OTP           –      One Time Pin
POS           –      Point of Sale
P2B           –      Person to Business
P2P           –      Person to Person
PSO           –      Payment Services Operator
SIM           –      Subscriber Identification Module
SMS           –      Short Messaging Service
USSD          –      Unstructured Supplementary Service Data

    A2F Consulting                                                      ii
Kyrgyz Republic: Women's Entrepreneurship Development Project - A2F Consulting
BOXES, FIGURES AND TABLES
Box 1: Understanding Electronic Banking ...................................................................................... 2
Box 2: Delivery Channels Risk Areas ............................................................................................. 10
Box 3: Delivery Channels Regulatory Framework ........................................................................ 11
Box 4: 2015 GSMA Report Key Findings ....................................................................................... 13
Box 5: Payment System Legislation Relevant to MFS................................................................... 21
Box 6: Telecom sector latest key developments .......................................................................... 22

Figure 1: Mobile Banking Ecosystem and Products........................................................................ 3
Figure 2: Mobile Financial Services Ecosystem Actors ................................................................... 4
Figure 3: ADC Landscape ................................................................................................................ 5
Figure 4: Delivery Channels Reach ................................................................................................. 6
Figure 5: ADC Technology Options ................................................................................................. 8
Figure 6: Mobile cash-in, cash-out, transfers and payments over M-Pesa .................................. 12
Figure 7: Mobile Money Statistics (GSMA 2015) .......................................................................... 13
Figure 8: Number of Live and Interoperable Mobile Money Services by Country ....................... 15
Figure 9: Number of Live Mobile Money Services by Region (2001-2015, year end) .................. 15
Figure 10: Mix of Mobile Banking Services by Volume and value ................................................ 16
Figure 11: Mobile Banking Average Monthly Transactions .......................................................... 16
Figure 12: Numbers of registered and active customer accounts, by region............................... 17
Figure 13: Different MFS Models in Emerging and Developing Markets ..................................... 18
Figure 14: Mobile Banking Building Blocks................................................................................... 19
Figure 15: Bai-Tushum Service Channel Architecture .................................................................. 27

Table 1: ADC Technology Components .......................................................................................... 7
Table 2: ADC Modes of Authentication .......................................................................................... 9
Table 3: Payment / Cash-out Instruments in Kyrgyzstan ............................................................. 20
Table 4: Mobile Banking Enablers ................................................................................................ 23
Table 5: Mobile Banking Readiness Scorecard (2013).................................................................. 25
Table 6: Mobile Banking Readiness Scorecard (2017).................................................................. 25
Table 7: Key Success Factors ........................................................................................................ 26
Table 8: Mobile Banking Model Options ...................................................................................... 31

       A2F Consulting                                                                                                                   iii
Kyrgyz Republic: Women's Entrepreneurship Development Project - A2F Consulting
1. INTRODUCTION
Most people and small businesses in rural Kyrgyzstan today do not fully participate in the
formal financial system. Particularly women entrepreneurs transact exclusively in cash, have no
safe way to save or invest money, and do not have access to credit beyond informal lenders and
financial institutions that offer microfinance loans. As a result, a significant amount of wealth is
stored outside the financial system and credit is scarce and expensive. This constraints women
entrepreneurs from engaging in economic activities that could transform their lives. Economic
growth suffers.

Mobile banking offers a transformational solution, and one that could be implemented rapidly
and without the need for major investment of costly additional infrastructure (see section “2.1.
Mobile Financial Services”). In the Kyrgyz Republic, financial institutions, mobile network
operators, and payment services providers are already using mobile phones and other readily
available technologies to offer basic financial services to customers. Many of these financial
institutions perceive mobile banking as an innovative technology capable of reducing costs and
increasing operational efficiency while increasing convenience for users and opening access to
finance for people at all income levels, in particular, for women entrepreneurs in the rural
areas. However, a strategic engagement with mobile network or payment operators is often a
new hurdle, as are is the existing regulatory framework1.

While banks offer mobile financial services that are connected to a formal bank account,
payment services operators provide services based on the purchase and transfer of electronic
money, and thus remain independent of the banking sector (only fully licensed banks can issue
electronic money). Currently in Kyrgyzstan, mobile network operators are not licensed to offer
mobile financial services, despite having a strategic advantage in the setup of an agent network
that could perform basic banking operations such as account opening and withdrawals.

The appropriate mobile banking model depends on many different factors and therefore must
be evaluated on a case by case basis. Each combination has its advantages and disadvantages,
and choice and success heavily depend on the starting position as well as the long-term goals.

This report assesses the potential of mobile financial services to increase financial access and to
deepen financial inclusion for women entrepreneurs, in the rural areas of the Kyrgyz Republic.
In particular, it provides: (i) Research and analysis of the international best practices on the use
of mobile services by microfinance institutions and bank; (ii) Market research on the mobile
banking and analysis of existing alternative delivery channels (ADC) used by banks and
microfinance institutions in the Kyrgyz Republic and (iii) assesses the real conditions of the use
of mobile banking and other alternative delivery channels (ADC) in the activities of the Bai-
Tushum Bank.

1
 For example, in the Kyrgyz Republic, microcredit institutions are only licensed to offer credit products hence not able to
immediately leverage mobile financial services as a means of offering savings, remittances and payment services.

      A2F Consulting                                                                                                     1
Kyrgyz Republic: Women's Entrepreneurship Development Project - A2F Consulting
2. MOBILE FINANCIAL SERVICES OVERVIEW
2.1. Mobile Financial Services – What is?
Mobile Financial Services (MFS) is a term generally used to describe any financial service
provided by the use of a mobile device. MFS are usually provided by banks, mobile network
operators (MNO) and payment services operators involving different technologies and concepts
to achieve the same purpose. There is no limit to the range of transactions and services for
which electronic money could be used, whether through mobile phone or card or other forms
of electronic banking. Box 1 provides the terminology commonly used in electronic banking.

 Box 1: Understanding Electronic Banking

 Mobile Banking (m-Banking) is the provision of account-based banking services to mobile devices. This
 includes two main services: first, the mobile device is used to access bank accounts without physically
 visiting a branch or using a computer to remotely manage accounts and conduct transactions. This
 service is very similar to internet banking and can be offered by simply opening the online banking
 homepage of a bank with a smartphone. A more user-friendly approach is to access via mobile banking
 applications. Often, mobile account management comes with a variety of informational functions, such
 as querying account balances or monitoring last transactions, as well as explicitly designed mobile
 services, such as SMS alerts, announcements, or authentication (e.g. one time pin). Second, mobile
 banking can be used to withdraw or deposit funds at ATMs. In this case, the mobile phone is used for
 identification and authorization of the account holder.

 Mobile Payments (m-Payments), is the transfer of money between two people (P2P), between a
 person and a business (P2B), or between the government and a person (G2P) via the subscriber’s
 platform, in which at least one party uses a mobile phone. M-payments can be used for
 micropayments, such as a utility bill, as well as to transfer larger sums, like in international
 remittances. They can be used for transactions from a business to a person, for example, for the
 payment of salaries. Most mobile payment systems are based on a prepaid balance that is transferred
 by SMS, near-field communication, or using codes, but postpaid or real-time payments are also
 possible. As distinct from some other forms of electronic banking, the transferred money is available
 immediately and, depending on the system, a bank may not need to be directly involved.

 Electronic Money (e-Money) refers to a balance of electronic money stored on a mobile device (a so-
 called m-float). It is a means of electronic alternative to cash and has monetary value stored
 electronically on receipt of funds, which is used for making payment transactions.

 Mobile Money (m-Money) is a subset of e-money referring to financial services and transactions made
 on a mobile phone that may or may not be tied directly to a personal bank account.

 Electronic Wallet (e-Wallet) is a specialized folder on an electronic device in which mobile money
 and/or the electronic representation of cards are kept. In connection with near-field communication, a
 mobile phone can then be used as a payment card, with the amount loaded on its SIM card while the
 bank account is charged at the same time. Such multiuse cards can be dedicated, such as electronic
 purses, or general, such as an application on mobile phones, personal digital assistants, or computers.
 One example is Google Wallet, which stores electronic cash in the form of an m-float as well as

     A2F Consulting                                                                                   2
Kyrgyz Republic: Women's Entrepreneurship Development Project - A2F Consulting
information on debit and credit cards, loyalty cards, various identification cards (such as for a parking
 lot or security), and others. The customer selects the preferred payment source, enters a personal
 identification number, and, via near-field communication, the data are transferred to the point of sale
 and the money transferred, either as an m-float or by sending electronic card information.

 Electronic Banking (e-Banking) Banking transactions conducted through computerized systems
 intended to speed operations, reduce costs, and allows bank’s customers to request information and
 carry out most retail banking services via computer, television, mobile phone, or via other electronic
 means.

Many mobile financial services users find the concept of MFS hard to grasp, especially if the
market environment is predominantly cash-based and characterized by low literacy rates.
However, in countries where virtual airtime top-up exists, the transition is easier, because the
concept is simple to test and trust is gained quickly. In reality, all transactions (Figure 1) that
are carried out “virtually” via mobile money have to be mirrored by the physical movement of
cash within the financial system. Therefore, reconciliations are carried out between the cash-in
/ cash-out points (agents), the accounts of the users and the bank accounts in which the funds
are pooled, either in real time or at least several times a day.

Figure 1: Mobile Banking Ecosystem and Products

     A2F Consulting                                                                                     3
Kyrgyz Republic: Women's Entrepreneurship Development Project - A2F Consulting
2.2. Mobile Financial Services - Ecosystem
Though the mobile financial services ecosystem continues to evolve, it is typically composed of
following actors represented in Figure 2.

Figure 2: Mobile Financial Services Ecosystem Actors

                        Regulators (Central Banks, Telecom Regulator)

               Account Providers                         Mobile Network Operators (MNO)

          Agent Network Managers                                   Agent Network

                 MFS Provider                                   Third Party Operators

            Merchants               Utility Service Providers        Government Agencies

                                            MFS Client

The Regulators. Financial and telecommunication sectors regulators design policy and provide
market operators supervision.

The Account Provider. The company that manages the client accounts. The account provider
typically is a financial institution (bank, MFI, etc.) or a non-bank MFS provider (e.g. MNO or
PSO). In the case of the latter, the client will have an account with the non-bank entity, but the
funds will have to be deposited with a partner financial institution (i.e. a regulated bank).

The MFS Provider. This is the company that hosts the mobile money platform over which
transactions are recorded. The FSP provider can be the same entity that manages the account.

The Mobile Network Operator (MNO). To deliver mobile financial services it is required the
existence of a mobile telephone network that makes it possible to carry the data from one
mobile device to another. The network also is how the interfaces of the different players
communicate and how they exchange information on the transactions carried out.

The Agent Network. This is the entity or network of entities that operate the cash service point
where the customer does cash-in and cash-out transactions. The agent can also register new
customers, conduct payment transactions, etc. A vital characteristic of a mobile money service
is the importance and easiness for clients to convert their virtual money to physical cash.
Hence, for the system to succeed, agents must have access to high volumes of cash (liquidity or
e-float) that they can use to convert cash to e-money and back to cash.

     A2F Consulting                                                                             4
Kyrgyz Republic: Women's Entrepreneurship Development Project - A2F Consulting
Third-party Operators. These include companies that provide services aimed at improving the
delivery of mobile financial services, such as, mobile money platforms, software companies and
even NGOs that have developed products based on mobile money transactions.

Agent Network Manager. These are companies that specialise in managing the agents of the
service. With the rise in popularity of the market, the number of players and the role they play
is expected to expand in the future.

Merchants, Utility Service Providers and Government Agencies. Provide value added services
through the mobile financial services channel.

The MFS Client. Is the end-user and/or beneficiary of the financial service.

2.3. Delivery Channels Evolution
Retail banking has traditionally evolved by introducing innovative products, services and
infrastructure. As customers demand more access means, anytime, anywhere and anyhow, the
evolution of distribution channels has simplified and increased access to financial products and
services as banking moves away from a traditional branch-based approach towards a more
 Figure 3: ADC Landscape                  diverse set of delivery channels and an increase level
                                          of integration.

                                                       Figure 3 shows the most common distribution
                                                       channels, their importance, and their usage. The
                                                       branch still remains central to providing individualized
                                                       service, but clients now visit these locations less often
                                                       because new technology allows simple and secure
                                                       transactions or other standardized procedures
                                                       through alternative systems. Diversification of
                                                       distribution channels allows clients to select the most
                                                       convenient channel and avoid time consuming and
                                                       sometimes costly branch visits.

                                                       A recent study 2 on retail banking customers
                                                       interactions with delivery channels, concluded that
                                                       customers interact with the mobile channel on
                                                       average 20-30 times per month, with desktop internet
                                                       banking 7-10 a month, with the ATM channel 3-5
                                                       times a month, whereas only walks into a branch 1-2
                                                       times per year.

2
    Source: Bank 3.0 by Bret King – September 2014 The Financial Brand

         A2F Consulting                                                                                       5
Innovation is introducing new players and business models, pushing financial institutions
towards investing in ADCs. In fact, the cost of servicing an account over the various channels
differs drastically showing again how the branch is the most expensive ($5/month/account) vs
less than $2 for mobile based agents, mobile accounts or mobile wallet.

2.4. Delivery Channels Reach
delivery channels reach relating two important dimensions: (i) diversity - from single channels
to multiple channels, and (ii) level of integration - from zero to seamless. Bai-Tushum currently
has a multiple channel offering (e.g. ATM’s, Bank Cards, Kiosks) but with limited channel
integration, hence is plotted in the early stages of multiple channel experience.

Figure 4 illustrates the delivery channels reach3 relating two important dimensions: (i)
diversity - from single channels to multiple channels, and (ii) level of integration - from zero to
seamless. Bai-Tushum currently has a multiple channel offering (e.g. ATM’s, Bank Cards, Kiosks)
but with limited channel integration, hence is plotted in the early stages of multiple channel
experience.

Figure 4: Delivery Channels Reach

                                                  Bai-
                                                Tushum
               Customers                         Today
               want access
               Anytime,
               Anywhere,
               Anyhow

More mobile money providers are actively tracking data4 on the gender and rural/urban split of
their customer base to capture the social and commercial opportunities of reaching these
underserved segments. Although this has not yet translated into greater penetration of mobile
money services, the fact that mobile money providers have begun to look at untapped market
segments is promising:

3
    Adapted from Accenture: Meeting customer expectations with an excellent multi-channel service delivery
4
    Source: GSMA Data from the 2015 Global Adoption Survey

         A2F Consulting                                                                                      6
•     Female customers – 39.2% of survey respondents reported the gender composition of
         their customer base. This is significantly higher than in previous years, indicating that a
         growing number of mobile money providers are tracking gender data. Among survey
         respondents who reported the percentage of female customers, the median value
         reached 37% in June 2015, with no significant change compared to previous years (39%
         in 2014 and 37% in 2013);

   •     Rural customers – 40.2% of survey respondents reported the urban/rural split of their
         customer base and this is also higher than in previous years. Among survey respondents
         who reported the percentage of rural customers, the median value reached 47.3% in
         June 2015, which is lower than what was reported in 2014 (53%), and similar to the
         reported value in 2013 (47%).

2.5. Technology Enablers
From the perspective of technology, ADC are enabled by the aggregation of four key
components: (i) a physical device (e.g. mobile phone, ATM, POS); (ii) an application running on
the device (e.g. mobile app); (iii) a communication channel used to exchange data between the
device and the core financial system; and (iv) an authentication mode used to confirm the
identity of the user of the channel. Table 1: ADC Technology Components shows a matrix of
options available per channel in terms of device, type of application, communication, and the
different types of authentication modes used per channel.

Table 1: ADC Technology Components

               Chanel Name          Device       Application     Communication Authentication
                                                                                   Mode
             ATM                ATM, HSM         Bespoke         LAN, VPN, 3G/4G     Card/PIN, OTP

             Internet Banking   Computer,        Web             Internet (mobile,   Username,
                                smart phone,                     land line,          password, OTP
                                tablet, kiosk                    wireless)
             Agent / Merchant   Computer,        Web, POS,       Internet (mobile,   PIN, bio,
                                phone, tablet,   Mobile          land line,          physical ID
                                POS                              wireless)
             Extension          Computer         Web, POS,       Internet (mobile,   PIN, bio,
             Services           phone, tablet,   Mobile          land line,          physical ID
                                POS                              wireless)
             m-Banking          Phone            Mobile          Mobile (3G/4G)      PIN, OTP

             e-Wallet           Phone, kiosk,    Web, POS,       Internet (mobile,   PIN, card,
                                POS, ATM         Mobile,         land line,          physical ID
                                                 Bespoke         wireless)

       A2F Consulting                                                                                7
(ATM)
           Call Center        Phone          IVR              Telecoms - Voice   Password

ADC technology is continuously evolving at a speed that is sometimes difficult to keep pace
with. Therefore, MFS providers need to invest sufficient effort prior to vendor selection
researching the available options and understanding the benefits and disadvantages of the
technology platform that they decide to pursue. Error! Reference source not found. illustrates
the range of technology options for                                                   each of
                                         Figure 5: ADC Technology Options
the     globally    available   ADC,
depending on whether the channel
will require a third-party integration
or can run on the Internet, on a
mobile platform, or through a
bespoke application such as ATM. As
the diagram shows, some channels
like the ATM provide very few
choices, while others such as mobile
channels offer many options at the
device,         application,      and
communication          levels.    The
technology selection needs to be
somewhat iterative, reverting back to
the strategy with informed decisions
about what is available in the market,
which will continuously change in this fast-moving ICT world.

In a standard delivery channel architecture, there are three key components to enable a
transaction: front office layer, back office layer, and an integration layer. In addition, a
communication channel and a mode of authentication will also be required.

    Front Office Layer            Front office Layer. The front-office component of the ADC
                                  technology platform is the software application that runs on
                                  the device, referred to as the front-end application for the
                                  purpose of this handbook. ADC applications can be based
                                  either on mobile, Web or bespoke platforms such as POS,
                                  ATM, and IVR. For instance, Internet banking runs on the
     Back Office Layer            back of a Web application. As with devices, mobile
                                  applications are the most complex, with four main types of
                                  applications.

                                  Back Office Layer. The back-office applications form a critical
                                  component of the ADC platforms and are typically used to
     Integration Layer            drive the front-end applications and devices. They also allow

     A2F Consulting                                                                            8
   Core Banking System
financial service providers (FSPs) to manage the channel users, define the products and services
offered via the channel, control the security of the channel, and monitor and report on the
channel activity and performance.

Integration Layer. The last component in the architecture involves integration between the
various systems involved in the delivery channels platform (such as CBS, Accounting and ERP)
and the technology driving the channel. In many cases, delivery channels solutions also require
multiple integrations with third parties (e-wallet providers, bulk SMS providers and national
switches), as well as several in-house systems (m-banking software, agency banking modules,
accounting software, CBS or loan portfolio systems).

Communication Channel. Delivery channels require the exchange of financial or non-financial
information between the FSP’s or PSO’s and the client, which typically occurs over
communication channels connecting the device and the back-office component of the delivery
channel. There are currently six communication channels available: LAN – local area network /
WAN – wide area network; Internet portals; Mobile data (3G/4G); USSD (GSM technology,
controlled by MNOs.); SMS (‘store and forward’ communication channel); IVR (computer
application with voice recognition); NFC (used for contactless payment transactions).

Mode of Authentication. The last component of delivery channels technology is the mode of
authentication, as illustrated in this table. This is of particular relevance, as one of the more
apparent risks associated with delivery channels is related to fraud arising from the
authentication of a customer’s or other user’s identity, and failures which may occur during this
process. Branch-based transactions can rely on well-trained tellers or staff whose judgement
can be used to confirm customer identity using scanned photos, physical ID cards, signatures,
and other tools. However, transactions initiated remotely through mobile devices or agents
often require enhanced means of verification.

Table 2: ADC Modes of Authentication

                 FACTOR TYPE      DEFINITION          OPTION AVAILABLE
                 Knowledge        Something that      Password, PIN, pattern, secret
                                  customer knows      question, image

                 Possession       Something that      Bank card, mobile phone,
                                  customer owns or    OTP/TAN, physical ID card
                                  has

                 Inheritance      Something that      Biometric characteristic
                                  customer is         fingerprint, iris scan

     A2F Consulting                                                                            9
2.6. Delivery Channels Risks
While MFS providers have existing risk management practices to safeguard their business, the
introduction of delivery channels may require a reassessment of these policies and the
introduction of new controls and risk monitoring systems. Certain characteristics of delivery
channels, such as a dependence on rapidly changing technology and their ubiquitous nature,
mean that new risks may be introduced (e.g. agent-level fraud). There is also the likelihood of
an increase in existing risks or their severity (e.g., in terms of dependency on the security of IT
systems).

 Box 2: Delivery Channels Risk Areas

 Typically, five areas of risk applicable to delivery channels have to be mitigated during the
  model decision process:

   •    Legal – the risk of lawsuits arising between any of the actors involved in the channel
        (customer, agent or MFS provider), either due to misuse of the channel, a lack of
        clarity of roles/ responsibilities, or breach of contracts or laws such as data
        protection/AML;
   •    Operational – fraud/theft committed via the channel, failure to manage the liquidity
        of agents and ATMs, unauthorized fees charged for use of the channel, poor quality of
        service, and loss of private data;
   •    Technological – insecure data storage, weak back-office security, insufficient
        communication protection, poor authentication/authorization of users, inadequate
        integration between systems/third parties, or a lack of service associated with
        hardware/software failures;
   •    Compliance – the risk of fines or loss of license as a result of noncompliance with laws
        or regulations, including AML, CFT, Agency Banking, Mobile Money, Consumer
        Protection, Regulatory Reporting;
   •    Reputational – a loss of customer and market share as a result of the occurrence of
        any of the risks described above;

2.7. Delivery Channels Regulation
Regulatory policy influences the market by mandating who can do what, where, and which
rules apply when it comes to financial services. Delivery channels are a complex topic for
regulators, as the space is constantly changing. It is the MFS providers’ responsibility to assess
and understand the obligations vis-à-vis the regulator and other relevant authorities.
Regulations governing the use and issuance of e-money/mobile money, mobile banking, agency
banking, Internet channels, and remote branches are the most obvious ones to consider. But

       A2F Consulting                                                                              10
others, such as regulations governing access to communications, interoperability, electronic
documents or signatures, KYC, biometrics, national ID, and AML/CFT must also be considered,
as they may impact some component of the channel.

    Box 3: Delivery Channels Regulatory Framework

       •   Agents - Authorization to use nonbank retail agents as the cash in/cash out point and
           principal customer interface;
       •   AML/CFT - Risk-sensitive anti-money laundering (AML) rules and rules for Combating
           Financing of Terrorism (CFT) adapted to the realities of remote transactions conducted
           through agents;
       •   E-Money - Appropriate regulation for the issuance of e-money and other stored-value
           instruments;
       •   Consumer Protection - Effective consumer protection to address the risks involved in
           electronic payments;
       •   Data Privacy and e-Security;
       •   Payment Systems - Inclusive payment system regulation and effective payment system
           oversight as branchless banking reaches scale;
       •   Competition - Policies governing competition among providers that balance incentives for
           pioneers to get into the branchless banking business and against the risk of establishing or
           reinforcing customer-unfriendly monopolies;
       •   Prudential Regulation - For Deposits & Payments;
       •   Telecom/Mobile Network Operator (MNO) Regulation;
       •   General Banking & Financial Access;

3. FINANCIAL INCLUSION AND MOBILE FINANCIAL SERVICES
3.1. Mobile Money as a Driver of Financial Inclusion
Mobile money is a powerful engine to deepen financial inclusion5. In 2015, the number of
mobile money services increased to 271 in 93 countries. Moreover, according to World Bank
data on global financial inclusion, mobile money services are available in 85% of countries
where the number of people with an account at a financial institution is less than 20%. Until
recently, policy efforts to develop financial services focused on the formal banking sector and
its intermediating function in converting savings into investment. This meant that the wealthy,
urban population enjoyed access to financial services while financial institutions neglected low

5
 The research analysis in this chapter is based on the data from the GSMA State of the Industry Report on Mobile Money
(December 2015).

       A2F Consulting                                                                                               11
income population segments (who generated low or negative returns) and rural areas (which
required costly bricks and mortar branches).

Barriers to financial inclusion on the demand side include:

       •     Affordability, such as high interest rates on loans, high premiums on insurance products,
             and minimum balances on accounts;
       •     Awareness and understanding, both as to availability of products and how they are
             structured, priced and used;
       •     Accessibility, with financial products typically offered in urban centres and near high
             income users, and subject to heavy bureaucratic processes; and
       •     Desirability, with many products not designed for the needs of low income users.

Figure 6: Mobile cash-in, cash-out, transfers and payments over M-Pesa6

According to the latest GSMA state of the industry report on mobile money, as of December
20157, there are 411 million mobile money accounts globally. Moreover, mobile money is

6
    Source: Safaricom 2014-5 results presentation.

           A2F Consulting                                                                           12
available in 85% of countries where the vast majority of the population lacks access to a formal
financial institution. This accomplishment, demonstrates the power of mobile, underpinned by
the important role mobile network operators and payment service operators have played in
building this industry. Additional key findings are described in Box 4.

Figure 7: Mobile Money Statistics (GSMA 2015)

The future success of mobile money, however, depends on the industry’s capacity to adapt to a
changing landscape. The findings from the 2015 report provide insights on both current and
future trends, giving better visibility on what is changing and how to adapt. In particular, four
trends will impact the industry’s evolution:

       •     While mobile money is more accessible than ever before, there is still an opportunity to
             reach underserved segments, particularly women and rural consumers;
       •     Further development of the mobile money ecosystem will be essential to diversify
             customer usage;
       •     Operational foundations and agent network management remain critical to digitize
             cash;
       •     Increased investment will be key for providers to compete in digital financial services;

Box 4: 2015 GSMA Report Key Findings

1. Mobile money is now available in 93 countries via 271 services;
2. More regulators are recognizing the importance of creating an open and level playing field
for mobile money services, although policy improvements are still required to ensure mobile

7
    In 2015, 107 mobile money providers from 67 countries participated in the survey.

           A2F Consulting                                                                           13
financial services reach the full addressable market and achieve financial inclusion. In 2015, 51
of 93 countries have an enabling regulatory framework;
3. Industry collaboration continues to gather steam. Nearly one-quarter of respondents
reported that they currently collaborate with other mobile money services, and a third
reported they were planning to collaborate in the next 12 months.
4. Agents remain the physical backbone and face of mobile money to digitize and disburse cash
(versus ATMs, banks, etc.), representing more than 90.5% of the cash-in and cash-out footprint.
They also account for a significant cost of doing business, with an average of 54.4% of the top
10 providers revenues going to agent commissions.
5. Mobile money is changing the landscape of financial inclusion. In 2015, 37 markets had ten
times more registered agents than bank branches and registered customer accounts grew 31%
to reach a total of 411 million registered accounts globally.
6. Mobile money providers processed just over a billion transactions in December 2015, which
is more than double what PayPal processed globally. Furthermore, active mobile money
customers conduct an average of 11.2 transactions per month and maintain a median account
balance of US$ 4.70, both increases from 2014.
7. While OTC continues to be a significant part of mobile money, the growth rate is slowing,
relative to the growth of account adoption. In South Asia, home to especially high OTC activity,
the 19% growth (year-on-year) of OTC is dwarfed by the 47% growth in registered accounts.
This promising sign suggests that the increased focus of providers to migrate OTC customers is
bearing fruit.
8. Cross-border transactions were the fastest growing product in 2015. Mobile money services
offering International money transfers saw the volume of cross-border remittances increase by
51.8%.
9. Fifteen providers reported revenues of more than US$ 1 million during the month of June
2015, up from 11 in June 2014. All but three of these providers are MNOs, and 12 have over
one million active accounts on a 90-day basis.
10. The majority of mobile money providers recognize the need for long-term investment in
their service. In 2015, three-quarters of respondents maintained or increased their investment
in mobile money over the previous year.
Source: GSMA 2015 State of The Industry Report on Mobile Money

3.2. Mobile Money Services - World Availability
Mobile money services are live in 64% of developing countries (86 of 135 countries), a small
increase from 2014 (61%). When looking at income classifications for these developing
countries, mobile money is most widespread in low-income economies (81%) compared to
lower-middle income and upper-middle-income economies, where mobile money is available in
71% and 47% of markets respectively. In 2015, mobile money was launched in four new
markets: Albania, Kyrgyz Republic, Myanmar, Peru, and Seychelles. Kyrgyz Republic and

      A2F Consulting                                                                                14
Myanmar are classified as lower middle-income, and Albania and Peru are upper-middle-
income.

Figure 8: Number of Live and Interoperable Mobile Money Services by Country

As the mobile money industry matures, the launch of new services has been slowing each
year. In 2015, 13 new services were launched, compared to 30 services in 2014 and 58
services in 2013. Sub-Saharan Africa continues to account for the majority of live mobile money
services (52%), however, more than half of new services launched in 2015 were outside this
region, primarily in Latin America & the Caribbean. Looking ahead, new mobile money services
are expected to grow by as much as 50% in Europe & Central Asia as well as the Middle East &
North Africa.

Figure 9: Number of Live Mobile Money Services by Region (2001-2015, year end)

While customers are becoming more active and the market size is growing, MFS providers
have yet to convince customers to actively diversify their usage patterns, so the industry
remains dominated by person-to-person (P2P) transfers and airtime top-ups. These two use

     A2F Consulting                                                                          15
cases are the foundational use cases for mobile money, the value of P2P transfers represents
71.5% 8 of the total mix, and airtime top-ups represent 66% of the total volume of transactions
(but only 3.6% of the value). These two use cases grew in volume by 27% and 24%, respectively.

Figure 10: Mix of Mobile Banking Services by Volume and value

Many MFS providers have begun to invest in new partnership models and fresh approaches to
diversify beyond P2P transfer volumes and values, with particular focus on: bulk disbursements,
lowest volume per month but largest value per transaction (Figure 11), merchant payments,
interoperability, cross-border mobile money remittances and transport payments.

Figure 11: Mobile Banking Average Monthly Transactions

8
    Source: GSMA State of the Industry Report On Mobile Money Dec 2015

         A2F Consulting                                                                      16
With a 31% increase in 2015, the number of registered mobile money accounts grew (almost
100 million new accounts) at nearly the same pace as in 2014 (33%), reaching a total of 411
million globally. However, South Asia and Sub-Saharan Africa showed the strongest growth in
adoption, accounting for 85% of all new accounts opened in 2015. In Sub-Saharan Africa, we
see the majority of growth coming from outside the mature mobile money markets of East
Africa 63% of all accounts opened in Sub-Saharan Africa in 2015 were in Middle, West, and
Southern Africa.

The penetration of mobile money is also deepening relative to mobile connections. In markets
where mobile money is available, 10% of mobile connections are now linked to a mobile money
account, compared to 8% as of December 2014. Across Sub-Saharan Africa, one in three mobile
connections is linked to a mobile money account as of December 2015. Of all sub-regions, East
Africa recorded the highest level of mobile money penetration (55%), which is more than twice
the level of smartphone penetration (19.4%). The most impressive growth occurred in West
Africa, where the percentage of mobile connections linked to a mobile money account
increased by nearly six percentage points in 2015 to reach 19.6%. Europe and Central Asia
remain the smallest regional market (1.7 million accounts) but has a huge growth potential.

Figure 12: Numbers of registered and active customer accounts, by region

     A2F Consulting                                                                        17
3.3. Mobile Financial Services Success Stories
Mobile financial services are delivered through different entities ranging from bank/financial
institution to Telco/MNO and third party or any hybrid type combination. See examples in
Figure 13.

Figure 13: Different MFS Models in Emerging and Developing Markets

   •     In Kenya, Vodacom/Safaricom’s M-PESA was initially designed as a pilot, conducted in
         partnership with the microfinance institution Faulu in 2003, to assess whether mobile
         phones could be used by microfinance institutions to better serve their clients;
   •     In the Philippines, Negros Women for Tomorrow Foundation, Inc. (NWTF) partnered
         with Smart Telecommunications in 2008 to provide eWallet services to its clients;
   •     In Tanzania, Zantel introduced Mimina Credit;
   •     Pesa Chap Chap instant e-loan product in Kenya;
   •     In Cambodia, Wing has established a successful MFS Agent model;
   •     In South Africa, MTN has partnered with Capitec Bank in a JV model;
   •     In Brazil, Banco do Brasil has been very successful with the agency banking model with
         the national postal office network.

       A2F Consulting                                                                        18
4. M-BANKING IN THE KYRGYZ REPUBLIC
4.1. Building Blocks of Mobile Banking
The success of mobile banking depends on completeness and maturity of several key building
blocks that make up the mobile money value chain. In order for basic services to be available,
each of the following five building blocks needs to be present in a market: (i) Market
Considerations, (ii) Mobile Capabilities, (iii) Financial Services, (iv) Mobile Money Enablers and (v)
Political and Economic Environment.

The first three building blocks address the core capabilities that need to be available for
customers. Mobile Money Enablers have a support function primarily to Mobile Capabilities and
Financial Services, but can also play a secondary role towards the end customer. Political and
Economic Environment underpins all building blocks.

Figure 14: Mobile Banking Building Blocks

4.1.1. Customer Considerations
Financial literacy is still very low particularly in the rural areas and amongst women, as
education levels in Kyrgyz Republic are very low. Besides that, the level of urbanisation is also
very low (37%), more than 85% of the population is unbanked.

Distrust in financial institutions, constraints in access to finance and a predominantly cash
payment transactions ecosystem are some of the considerations to take into account in the
decision process of a mobile banking business model.

     A2F Consulting                                                                                 19
4.1.2. Financial Services
The financial regulation index is significantly strengthened in the last few years, with some
level of investment achievements in the banking infrastructure, however remains low
compared with OECD countries.

The finance sector is comprised 25 banks and 323 branches with total assets of about 178
billion KGS9, however only 18% of adults of which 19% women actually have a bank account
opened. The microfinance market is large, with 99 licensed microcredit/microfinance
institutions and 114 licensed credit unions, responsible for at least one-quarter of the total
credit to the private sector. Although the commercial banks give the microfinance institutions
heavy competition, the role of the latter and credit unions in providing credit to micro, small,
and medium-sized enterprises and the rural population has increased significantly in recent
years. Some level of consolidation in the financial sector is expected in the short/medium term.

Table 3: Payment / Cash-out Instruments in Kyrgyzstan

       Payment / Cash-out Instruments                                                                  Number
       Automated Teller Machines (ATMs)                                                                          1,319
       Main kiosk players (some are owned by banks and
       installed at the branches) – 1,400 of which are located in
       Bishkek and Chui region, with only a few terminals
       existing in the south region. In average, one month of
                                                                                                                 1,500
       payments in the amount of 1,2 billion KGS are made
       through the payments terminals/kiosks in Kyrgyzstan10.
       Main payment providers are: Mobilnik, Qiwi and
       Quickpay.
       POS (of which 6,014 are located at retail merchants)                                                      6,014

                                                                                                              452,643
       Visa and MasterCard International Cards
                                                                                                                15,729

       Elkart (National Payment Card – commission free)                                                       635,152

       Zolotaya Korona Card – is Russia's largest payment
                                                                                                              558,781
       system also operating in Kyrgyzstan

       Interbank Processing Center (IPC), controlled by NBKR –
                                                                                                                   n/a
       optional business case
       International Remittances                                                                           1.54 million
       Domestic Money Transfers                                                                               137,700

9
    Source: National Bank of Kyrgyzstan (31 March 2017)
10
     Source: These data were presented by the Association of payment system operators at the end of 2016

         A2F Consulting                                                                                                   20
The remittance market is quite competitive in Kyrgyzstan: Аnelik, Blizko, Contact, Migom,
MoneyGram, Western Union, Unistream, Gold Crown, Leader, Quick Post, Allure, Xpress
Money, Privat Money, INTERexpress, and other remittances done through KyrgyzPost.
However, the majority of the providers are managed from Russia, and their main operation is
the money transfer between Russia and Kyrgyzstan, mostly done through Gold Crown
company, managed from Russia. The most recurring money transfer services provided by the
players are:

   •     C2C – (cash to cash) most prevalent option;
   •     C2M – customer can top up mobile account (air time only), but from this mobile
         account customer can’t make any payments;
   •     C2M – client can top up an e-wallet, enter his e-wallet from a mobile using a mobile
         application and pay for different services;
   •     M2C – available only from Russian sim-card by sending an SMS, not available from
         Kyrgyz sim-card;
   •     M2M – transfers from e-wallet to e-wallet using mobile application is possible;

As of 09 June 2015, the National Bank of the Kyrgyz Republic has provided licenses for: (i)
rendering of services on accepting, processing and delivery of financial information (processing,
clearing) on payments and settlements of third persons to participants of payment systems of
the present processing, clearing center and (ii) rendering of services on accepting and making
payments and settlements for goods and services; to the following companies: Interbank
Processing Center (IPC); Momentary Payments Integrated System; Mobilnik" (Cell Phone);
Mobilnyi Koshelek; BM Technologies; KYRTELSAT; Quickpay System and Alimbek JSM.
   Box 5: Payment System Legislation Relevant to MFS

  • Only fully licensed banks can issue electronic money and perform operations on accounts
    opened on the basis of bank account agreements;
  • Banks may enter into agency agreements with non-financial institutions and non-bank financial
    institutions to provide services to the public on payments, settlements (including payments and
    settlements with using bank cards), remittances, distribution of electronic money in accordance
    with the regulatory acts;
  • The holder of electronic money can purchase goods and services via electronic money payments
    and receive cash in exchange for electronic money in special devices for acceptance and service
    of electronic money instruments;
  • The record of the movement of electronic money is carried out by the issuer (Bank) through
    opening a settlement (current) account to record electronic money in the bank in accordance
    with the agreement for opening and service of accounts;
  • The use of electronic money in the settlements shall be carried out by the holder of electronic
    money transferring to business entity or person (acceptor), which makes the exchange of its
    products/services for electronic money and has the special equipment (software and hardware)
    for receiving and accounting payments using electronic money;
  • Software and technical tools used in the system of settlements with electronic money must
    comply with regulatory of the Bank of Kyrgyzstan ensuring information security;

       A2F Consulting                                                                                 21
4.1.3. Mobile Capabilities
Telecommunication infrastructure in general is good, as the sector has been part of the final
phase of a large scale privatisation program that has been steadily progressing in the country
since 1992. Fixed broadband penetration continues to grow strongly but from a very small
base. It reached 4.4% in 2016, up from 2.4% in 2013 and 0.9% in 2012. The mobile subscriber
growth rate in 2015 and 2016 was a flat 0.2% as the market reached 7,595,000 subscribers in
2016 11. The mobile market is now mature. Further slow growth is also predicted over the next
five years to 2021.

Over the past few years there has been particularly strong growth in mobile broadband
subscriptions. This phenomenon is rapidly changing the shape of the internet market. The
active mobile broadband subscriber penetration reached 33% in 2016. In fact, the 4G mobile
market is slowing growing as major operators launch services. As of 2015 the percentage of
population with mobile data coverage was: 2G 97.8%, 3G 59% and LTE/4G 1.6%.

During 2012 to 2016 the internet penetration in Kyrgyzstan has been increasing steadily,
increasing from 23% in 2012 to 30% in 2015 and 32% in 2016. The percentage of households
with the internet has risen from 8.7% in 2013 to 16.5% in 2016. Furthermore, the international
internet bandwidth has risen significantly over the last five years rising from 1,200 Mb/s in 2010
to 12,700 in 2015.

Internet access is also good, with a user penetration rate of 21%, mostly through internet cafes,
as only 4% of households own a computer (World Bank and ITU 2013). The two largest mobile
network operators, Beeline and MegaCom, account for 90% of total subscribers. O! the new
private mobile operator is growing market share but still limited to the largest cities.

     Box 6: Telecom sector latest key developments

     •   O! expanded LTE overage to the cities of Osh and Jalal-Abad, adding to its existing coverage in
         Bishkek and Naryn;
     •   Megacom launched its 4G LTE network in the cities of Bishkek, Osh and Jalal-Abad;
     •   Beeline introduced its 4G LTE network to all regions across the country;
     •   The NCA disconnected all non-registered SIMs from 1 February 2016;
     •   VimpelCom Ltd partnered with ZTE Corporation to build a complete virtual network
         infrastructure providing 4G/3G/2G mobile data services.

4.1.4. Mobile Banking Enablers
Under the law, all electronic payments take place on the basis of specific agreements
between the payment parties. Although still limited, the existing regulation on the mobile
banking sector has become available since the end of 2011, and it was the second most popular

11
     Source: BuddeComm Research 2016

         A2F Consulting                                                                                    22
remote banking service after internet banking, according to the central bank. However, mobile
banking is for the most part limited to SMS alerts on account activities and monitoring account
balances. In 2013, Geopay (an international private investment start-up) was the first operator
of mobile money in the Kyrgyz Republic, introducing a mobile wallet service. Today, there are
several payment services operators licensed to operate m-wallets/e-wallets in partnership with
commercial banks responsible for the issuing of e-money.

Table 4: Mobile Banking Enablers

 Mobile Banking Enablers                                                        Number
                                                                                   Elsom is market
                                                                                 leader with: 97,000
 There are 4 main m-wallets: Mobilnik (3rd party driven),                           subscriptions
 Elsom (bank driven, Doshcard (3rd party driven), Umai                           or 1.6% population
 (3rd party driven).

 Additionally, there are several other e-wallets e.g.
 Yandex, Webmoney, Kyrtelsat, Geopay (USA based), e-
 Pay (virtual internet wallets) in the market mostly
 operated by Russian and Kazakh based companies used
 mostly for gaming, phone top-up or utility payments.

 Agent Networks – 2 main agent network players with         Asisnur (National
                                                                                    2,500 agents
 national coverage – require a payment services                 Coverage)
 operator license and/or agent banking license                 Kyrgyz Post       922 postal offices

4.1.5. Political and Economic Environment
The Kyrgyz Republic has
6.02 million inhabitants
and      a     very    low
population density of 30
inhabitants per square
kilometre12. The country
is among the poorest in
world and has the
second lowest GNI per
capita ($1,170) after
Tajikistan in the region13.
Poverty incidence is high

12
     Source: ADB Basic Statistics 2017
13
     Source: World Bank Data 2015

         A2F Consulting                                                                                23
at 32.1% and trending upward. The size of the informal economy is significant and limits the
state capacity to deliver governance and strong institutions, which in turn discourages
participation in, and expansion of, the formal economy.

Services are the most important sector, at 52.5% of GDP, followed by industry with a
growth rate of 5.9% from 3.8% in 2016 as gold production more than doubled, setting
declines in textiles, apparel, and electricity generation 14. Agriculture increased by 3.0% thanks
to gains in crops and livestock, though well below the 6.2% expansion in 2015. Services growth
slowed to 3.0% from 3.7% in 2015 although trade growth increased to 7.6% from 7.1%.
Construction rose by 7.4%, down from 16.3% in 2015, as growth in capital investment slowed
even more to 3.8% from 14.0%. Currency appreciation and higher remittances (22% rise)
curbed inflation and the current account deficit. Weak exports slowed growth marginally and
average inflation plunged to 0.4% in 2016 from 6.5% the previous year (estimated 5% in 2017)
as consumer prices fell by 0.5% from December 2015 to December 2016. Growth is projected to
slow to 3.0% in 2017 before recovering to 3.5% in 2018 with faster regional growth. The recent
Eurasian Economic Union membership poses both challenges and opportunities.

4.2. Country Readiness
For each of the building blocks a set of key success factors - see Table 7 (descriptors, indices,
key performance indicators etc.) - can be identified. There is no quantitative analysis
framework that can automatically calculate the likelihood of success of each of the mobile
money services due to the following reasons:

       •     The interplay of primary building blocks with enablers and overall environment create a
             variety and multitude of opportunities to establish mobile money services;
       •     Innovations in technology, services and business models for mobile money services
             happen on a daily basis, hence, it’s difficult to codify a set of likely successful business
             models into a simplistic quantitative model;
       •     Market experience has been that it’s difficult to replicate a business model that was
             successful in one country in another one

The collection of key success factors will provide Bai-Tushum an analysis of challenges and
opportunities for mobile money services.

This model is based on an EBRD mobile money services study conducted in January 2013. The
study then concluded that the Kyrgyz Republic was not in a ready state for mobile banking
ecosystem investment.

14
     Source: ADB Outlook 2017

           A2F Consulting                                                                              24
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